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What's up everyone and welcome to another episode of the ditty diaries. Previously we saw
the complaint from Latoya Grayson. Well now she has filed an amended complaint to the tune
of 72 pages. So we'll keep the winging short and we'll just dive right in case number
24-cv-09857-jav. Latoya Grayson plaintiff. Verrs Sean Combs, Bad Boy Entertainment Holdings,
Sean John Clothing, Atlantic Records, Mike Sabis, Delta Airlines, Crowbar Night Club, NYC Crowbar,
Penske Media Corporation, Vi Magazine, Perry Broadcasting, and Publishing, KJAMs, Best Buy
Company Incorporated, Rodgersmith Hotels, and John and Jane Doe's 1-10. Amended Can Plaint,
Jerry Trial Demand, plaintiff Latoya Grayson, or Miss Grayson, buy-and-thriller attorneys,
hereby alleges and divers of the defendant Sean Combs, Bad Boy Entertainment Holdings, Sean John
Clothing, Atlantic Records, Mike Sabis, Delta Airlines, Crowbar Night Club, Penske Media Corporation,
Vi Magazine, Perry Broadcasting, and Publishing, KJAMs 105.3, Best Buy Company Incorporated,
Rodgersmith Hotels, John and Jane Doe's 1-10, collectively referred to as defendants,
alleges upon information and belief as to all other matters that follows.
Preliminary Statement. On November 16, 2023, Cassie Ventura filed a 35-page lawsuit
in which he exposed defendant Combs of subjecting her to nearly a decade of physical, sexual,
and emotional abuse punctuated by rape, sex trafficking, and being forced to engage and drug
fueled non-consensual sexual encounters with other men. Or, narrowly, when a lawsuit,
such as the one Miss Ventura has filed that involves events that took place long ago,
witnesses are few and far between, and evidence is hard to muster. Not so for the claims
brought against defendant Combs. Within minutes of the filing of Miss Chura's claims,
were confirmed by various witnesses, including a rival musician whose car defendant Combs blew up,
various individuals who observed defendant Combs, beat Miss Ventura, and a video released by CNN
showing defendant Combs physically abusing, battering, and assaulting Miss Ventura.
Since Miss Ventura's brave decision to file a lawsuit against defendant Combs,
defendant Combs has accumulated numerous lawsuits across the country for the same conduct alleged by
Miss Ventura. The number is growing and continuous in various jurisdictions throughout the United
States. In September of 2024, defendant Combs was arrested in the Southern District of New York,
where he's currently being held without, with no bond, while awaiting various serious criminal
charges. Plaintiff now alleges she too is one of the many victims of defendant Combs and the
other defendant's name herein. Plaintiff can support her allegations and is suffered extreme
emotional distress, impacting nearly every aspect of plaintiff's life and personal relationships.
Given all of the brave individuals who have come forward against defendant Combs, Plaintiff
is also doing the same. Plaintiff brings this action seeking injunctive declaratory and
monetary relief against defendants and violation of the Victims of Gender Motivated Violence Protection
Gender Motivated Violence Act NYC admin code section 10-1101
Jurisdiction in venue. This court has personal jurisdiction over the defendants
under and consistent with the constitutional requirements of due process
and that the defendants acting directly or through as agents or apparent agents committed
one or more of the following. The transaction of any business within the state, the making of any
contract within the state, the commission of a torturous act within this district, and the
ownership used or possession of any real estate in this state. As of the date of this filing,
defendants have consistently and purposefully availed themselves of the privilege of conducting
activities within New York, thus invoking the benefits and protections of New York law.
In return for these benefits and protections, defendants must submit to the burdens of litigation
in New York. This litigation arises from or relates to the torturous activities of the
defendant and what they visited upon plaintiff in New York. This torturous conduct violated
United States Federal Rico laws and other laws requiring defendants to litigate these claims
in the district does not offend traditional notions of fair play and substantial justice.
Plaintiff's claims arise from conduct occurring by defendants in New York. This court has jurisdiction
over the action pursuant to US Code 28 section 1331 authorizing original jurisdiction over
civil actions which arise under the Constitution, laws, or treaties of the United States.
This court also has subject matter jurisdiction under US Code 28 section 1331 and supplemental
jurisdiction under US Code 28 section 1367 because the state law claim forms part of the same case
and controversy as the claims arising under the federal statute.
Pursuant to US Code 28 section 1391 BC and 1400A venue is proper in this court because of
substantial part of the events or emissions giving rise to this action alleged herein occurred in
this district. Plaintiff brings suit against defendant pursuant to the NYC Gender Motivated Violence Act
NYC admin code section 8-901 to redress the substantial and lifetime injury she has suffered.
This court has personal jurisdiction over defendants and each of them because defendants have
purposefully directed their own lawful conduct to this judicial district and have conducted substantial
business in this judicial district procedural requirements. The NYC Victims of Gender Motivated
Violence Protection Act the NYC Victims of Gender Motivated Violence Protection Act
NYC Gender Motivated Violence Act created a lookback window on March 1, 2023 which runs for two
years for survivors of gender motivated violence allowing them to sue their abusers regardless
of when the abuse occurred NYC admin code section 10-1105 the NYC Gender Motivated Violence Act
revives any claims against a party who commits directs and ables, participates in or conspires in
the commission of a crime of violence motivated by gender as a cause of action against such party
in any court of competent jurisdiction. The appellate division has held that sexual assault is an
act of gender motivated violence under the law as coerced sexual activity is dehumanizing and
fear inducing. Malice or ill will based on gender is apparent from the alleged commission of the act
itself. Animus in here is where consent is absent, briefs verse haggis.
The conduct of defendants in battering and assaulting plaintiff constitutes a crime of violence
and a crime of violence motivated by gender against plaintiff as well as specifically at
defendant comms direction enabling, participating and conspiring in the commission of a crime of
violence motivated by gender defined by the NYC Gender Motivated Violence Act.
Given the extensive media coverage of the criminal trial brought by the Southern District of New
York and numerous civil lawsuits filed in both federal and state against defendant comms,
defendants were put on notice of the multiple allegations made against defendant comms including
drug trafficking, sex trafficking and racketeering. The parties defend in Sean Combs.
Defendant Combs is currently an inmate at Metropolitan Detention Center in Brooklyn, New York.
Defendant Combs maintains residences in California and Florida and is believed to be a resident
of the state of California. At all relevant times to the occurrences herein, defendant
Combs was a citizen and resident of the state of New York. Defendant Combs is a rapper and a record
executive popularly known by his stage name Puff Daddy, Puffy Puff P. Diddy, Diddy brother love or love.
Defendant Combs rose to prominence in the music and entertainment industries over the decades
and is regularly referred to as a hip-hop mogul. Defendant Combs was first accused of acts
described in this complaint by his longtime paramour and former BBE artist, Cassie Ventura,
on November 16, 2023. Defendant Combs is a Grammy award-winning musician rapper and producer,
Defendant Combs founded Defendant BBE. In 2008, two years after the assault and battery on plaintiff,
Defendant Combs was the first male rapper to get a star on the Hollywood Walk of Fame.
In 2022, Forbes estimated that Defendant Combs was one of the wealthiest hip-hop artists in America,
and that his net worth was over $1 billion. Upon information and belief, Defendant Combs has a long
history of committing physical and sexual violence against women and men, similarly alleged
in this complaint, as documented publicly, available in nine lawsuits across the country and
extensive media coverage. Defendant Bad Boy Entertainment Holdings Incorporated Defendant bad
boy entertainment holdings, is a domestic business corporation licensed to do business in
New York. Defendant Bad Boy entertainment holdings is a domestic business corporation licensed to do
business in New York. Defendant Bad Boy Entertainment holdings, is a musicmedia and entertainment company
founded and owned by Defendant Combs, bad boys incorporated, and headquartered in New York.
Defendant BBE has been named in several lawsuits where Defendant Combs has been accused
of claims of sexual abuse and sex trafficking, as alleged in the instant complaint.
Defendant Sean John Clothing LLC
In 1998, Combs founded Sean John, which has a retail sale of over 450 million.
As CEO and president of the company, Defendant Combs was representing Sean John when he
conspired to have plaintiff assaulted. Sean John Clothing LLC is a domestic liability company
licensed to do business in New York. Defendant Atlantic Records
Defendant Atlantic Records Recording Corporation is a domestic business corporation licensed
to do business in New York and headquartered in New York. Defendant Atlantic Recording Corporation
is a domestic business corporation licensed to do business in New York since 1967.
Defendant Atlantic Recording Corporation is a music media and entertainment company incorporated
and headquartered in New York. Defendant Atlantic was responsible for and facilitated the event
that learned plaintiff, Defendant Combs, in New York where she was injured. Defendant Mike Savis
Defendant Mike Savis upon information and belief is a citizen, resident, and is domiciled in the
state of New York. Defendant Savis upon information and belief and confirmed by Defendant Savis linked
in page was an employee of Defendant Atlantic at all relevant times. Nicole hosts Easter every year.
That's why she shops at BJ's wholesale club, stocking up on spiral ham baked goods, fresh flowers,
candy, and five dozen eggs. Nicole's not worried because she knows she can save big and get it all
done in one trip. It's like winning the Easter egg hunt. When you save everyone wins. Get a
$15 digital coupon when you spend $150 in one transaction now through April 5th. Visit
BJ's.com slash Easter coupon for details. BJ's your Easter destination. Hi, this is Alex Cantrowitz.
I'm the host of Big Technology podcast, a longtime reporter and an on air contributor to CMBC.
And if you're like me, you're trying to figure out how artificial intelligence is changing the
business world and our lives. So each week on big technology, I bring on key actors from
companies building AI tech and outsiders trying to influence it. Asking where this is all going,
they come from places like Nvidia, Microsoft, Amazon, and plenty more. So if you want to be smart
with your wallet, your career choices, and meetings with your colleagues and at dinner parties,
listen to big technology podcast wherever you get your podcasts. Defendant Savis and his
employment capacity with Defendant Atlantic was responsible for promoting coordinating and
arranging promotional contests, which was the cause of plaintiffs injuries. Defendant Delta Airlines
Delta. Defendant Delta operates an airline licensed to do business in New York with its headquarters
located in Atlanta, Georgia. Defendant Delta's ongoing relationship and participation with
Defendant Combs, Atlantic and KJMs, was to transport potential victims to Defendant Combs,
was corrupt, exploitative, to plaintiff and to benefit Defendant Delta and other members of
the enterprise. Defendant Delta in their capacity as a common carrier was responsible for transporting
and arranging the delivery of plaintiff and possibly all contest winners to defendant which ultimately
led to plaintiffs injuries. Defendant Crowbar Nightclub. Upon information and belief,
Defendant Crowbar is owned by Big Chicago Incorporated. Upon information and belief, Defendant Crowbar
was founded by Ken Smith and Colin Fortis. Upon information and belief, Defendant Crowbar
opened in New York in 2003 and closed in 2007 after numerous violations for drug and assault cases.
Upon information and belief, Defendant Crowbar is a nightclub located in New York. Defendant Crowbar
owed a duty to plaintiff to provide her a safe environment to protect plaintiff from foreseeable risk.
Defendant Crowbar was responsible for and hosted the event that learned plaintiff to Defendant Combs
in New York where she was injured. Defendant via magazine. Upon information and belief,
Defendant Vibe runs a magazine licensed to do business in New York with its headquarters in New York.
Defendant Vibe has an ongoing relationship with Defendant Combs. All of Defendant
center prizes include BBE and SJC was corrupt and exploitative to plaintiff for the benefit
of Defendant Vibe and other members of the corrupt organization. Defendant Vibe's ongoing
beneficial relationship with Defendant Combs dates back as far as 1993. Defendant Penske
Media Corporation. Upon information and belief, Defendant PMC is the owner and parent company
of Defendant Vibe. Upon information and belief, Defendant PMC is a Delaware Corporation,
with its headquarters in California. Defendant PMC does business in New York through its ownership
of Defendant Vibe and its distribution of several media outlets that are distributed, marketed,
and consumed in this jurisdiction. Defendant Perry Broadcasting and Publishing, KJAMS.
Defendant KJAMS is owned by Perry Broadcasting and Publishing. Defendant Perry Broadcasting and
Publishing owns and operates a radio broadcast station in Oklahoma on FM radio called KJAMS.
Upon information and belief, Defendant KJAMS is an Oklahoma domestic business
corporation licensed to do business in Oklahoma. Defendant KJAMS was responsible for
and facilitated the event that fraudulently enticed plaintiff to New York where she was injured.
Best Buy Company Incorporated. Defendant Best Buy is a retail electronics company
that's headquartered in Richfield, Minnesota. Defendant Best Buy is a retail electronics company
that's been in business since 1966. Defendant Best Buy does business in New York throughout
its ownership and operation of retail stores in this jurisdiction. Defendant Roger Smith Hotel.
Defendant Roger Smith Hotel operates a hotel licensed to do business in New York and located
in New York. Defendant Roger Smith hotels ongoing relationship and participation with Defendant
Combs, Atlantic and KJAMS was to provide lodging to potential victims to Defendant Combs,
was corrupt, exploitative, to plaintiff and to benefit Defendant Hotel and other members of
the enterprise. Defendant Roger Smith Hotel in their capacity as a common carrier was responsible
for the accommodation of plaintiff and all other contest winners, which ultimately led to plaintiff's
injuries. Defendant's John and Jane Does 1-10. Upon information and belief plaintiff alleges
that Defendant Does 1-10, inclusive, are other parties not yet identified who have violated plaintiff
by assaulting, battering and threatening her, conspired and are aided and abetted the Defendant Combs
and other defendants in their participation in a corrupt organization that caused plaintiff's injuries.
The true names, whether corporate, individual or otherwise of Defendants 1-10, inclusive,
are presently unknown to plaintiff, which therefore sues said defendants by such fictitious names
and will seek leave to amend this complaint to show their true names and capacities
when she has ascertained, pursuant to CPLR section 1024. Upon information and belief,
plaintiff believes that all the Defendant Does 1-10 are citizens of the state of New York. Upon
information and belief plaintiff believes and there on alleges that at all times relevant here too,
each of the Defendant Does 1-10 were the agent, affiliate, officer, director, manager,
principal, alter ego, and or employee of Defendant Combs, BBE, SJC, Atlantic, Delta,
Crowbar, PMC, Vibe, KJAMs, Best Buy, and or Hotel, and was at all times acting within the scope
of such agency, affiliation, alter ego relationship, and or employment. An actively participated in
or subsequently ratified and adopted or both, each and all of the acts are conduct alleged
with full knowledge of all the facts and circumstances, including but not limited to full knowledge
of each and every violation of plaintiff's rights, and the damages to plaintiff proximity
caused thereby. The limitations article 16 of CPLR do not apply because one or more of the
exceptions set forth in CPLR section 1601 and or 1602 apply. All right, we're going to wrap up
right here with episode one, and in the next episode we're going to pick up with plaintiff
Latroya Grayson. All of the information that goes with this episode can be found in the description
box. What's up everyone and welcome to another episode of the Diddy Diaries. In this episode,
we're going to pick up where we left off with the Latroya Grayson amended can plan against Diddy.
Plaintiff Latroya Grayson. Plaintiff is an individual who is a citizen of the United States and
a resident and domiciled in Oklahoma. Plaintiff at all times relevant to the action was a resident
and domiciled in the state of Oklahoma. Plaintiff at all times relevant to this action was 23 years old.
Plaintiff had never traveled to New York City prior to the events described herein,
and otherwise would not have traveled to New York City without being enticed by the scheme of
defendants. Plaintiff was the guest of her half-sibling who won the contest on defendants KJAM's
radio station and agreed to accompany her sibling on what she believed to be a legitimate,
all expenses paid trip to a Diddy White Party in New York in 2006, and her life has been
detrimentally impacted ever since. Factual allegations. The radio contest.
In late 2006, defendants KJAM's began promoting a contest on its radio station 105.3,
Jams in Oklahoma sponsored by Defendant Combs, BBE, Atlantic and Delta, offering the winner a prize
of an all-expenses paid vacation for two to New York City to attend a Diddy White Party.
At this point, Defendant Combs' White Parties were legendary and ongoing as they had begun in 1998
and were in full swing by 2006. Eagerly Plaintiff and her sibling tried to win the KJAM's radio contest.
Eventually, Plaintiff's sibling was able to win the contest. The contest included Roundtrip
Airfare for the winner and the guest, one hotel room in New York, and two tickets to attend Diddy's
White Party in New York. Upon information and belief, this was not a traditional White Party thrown
by Defendant Combs, as those typically occurred during Labor Day holiday, but a separate promotional
party. Initially, the party was scheduled for October 6, 2006, but was then rescheduled without
warning or explanation. Plaintiff received an initial letter from Atlantic providing instructions
on how to attend the party and the details of the party dated for the original date of the White
Party. The party was then scheduled for October 16, 2006. Plaintiff was provided a plane ticket
issued by Delta for departure on October 16, 2006, from Tulsa to New York JFK airport,
returning to Tulsa the next day on October 17, 2006. In addition to the date of the party being
rescheduled, the theme of the party was also changed from a White Party to a Black Party. Due to
the change of a required colored attire to attend the party, Plaintiff was forced to purchase the
new outfit that was within the new theme and dressed requirements for admittance. Plaintiff and
her sibling had never been to New York City and were excited about their trip and their attendance
at a celebrity party hosted by Defendant Combs. Plaintiff and her sibling rented a limousine to
transport them from the airport to the hotel in an effort to make the most of their free trip.
Upon arrival in NYC, Plaintiff checked into the pre-arranged hotel, the Roger Smith hotel. Plaintiff
was required to pay a cash deposit to the hotel which was provided and paid by Atlantic, the Black
Party. Plaintiff changed into her requisite black outfit and met the Transportation van arranged
by Atlantic employee Mike Savis downstairs at the hotel. Along with Plaintiff and the Transportation
van arranged by Atlantic employee Mike Savis were several other contest winners who won the same
contest in their home cities and were subsequently flown to New York as radio contest winners for
this ditty Black Party. Upon arrival at the location where the Black Party was thrown, Plaintiff and
the other contest winners were forced to wait in line for entrance into the party. Plaintiff and
other contest winners were approved for entry by security based on their appearances and their
attire. Individuals were not let into the party based on their position in line but based on
their attractiveness and attire. After waiting in line for approximately 45 minutes, Plaintiff was
finally granted entry into the party, even though Plaintiff was granted entry or sibling was not,
and Plaintiff was separated from her sibling before realizing her sibling had not been
granted entry into the party. Plaintiff did not see, nor does she remember seeing her sibling
at the party during Plaintiff's time inside the party. While Plaintiff waited in line for entry
to the party, several celebrities walked the red carpet. While inside the party, Plaintiff noticed
other celebrities whose attendance was confirmed by a press coverage of the event. While inside the
party, Plaintiff took pictures with some of the celebrities and attendants, including rappers,
babs from making the band and bone crusher. At one point, Plaintiff met an individual who
were purported to be defendant comms assistant and he befriended Plaintiff, who was alone.
While at the party, defendant Diddy is seen giving a party goer, a party goer he seems
particularly fond of a drink. While at the party, there was no bar for party goers to get drinks.
Instead, pre-May drinks were being circulated throughout the party by waitresses.
After less than two pre-May drinks provided by the waitresses, Plaintiff began to feel sick and
tried to go to the restroom. The next memory Plaintiff has is awakening at St. Vincent's Medical
Center of New York. Plaintiff has no memory or recollection on how she ended up at the hospital.
When Plaintiff regained consciousness at the hospital, she noticed her shirt was ripped,
her underwear was missing, she was not wearing any shoes, and the money that she had traveled with
was stolen. The only money Plaintiff had remaining was a $20 bill. Plaintiff was admitted to the
St. Vincent's Hospital, treated, and released. Upon release from the hospital, Plaintiff a tourist
had no way of knowing how to return to her hotel, as smartphones were not commonplace at the time.
Plaintiff remained in the waiting area of the lobby of the hospital after her release for so long
she was eventually forced out by hospital security. Plaintiff was able to find a book of matches
in her purse bearing the name of the hotel where she was domiciled. Plaintiff then held a taxi
and returned to the hotel using the $20 bill she had left in her purse.
When Plaintiff returned to the hotel, she called a friend and explained she was not sure what
had happened to her, but Plaintiff believed she was drug-disalted robbed, with no memory of how she
arrived at the hospital, as her last memory was being at Diddy's Black Party.
Hi, this is Alex Cantrowitz. I'm the host of Big Technology podcast, a longtime reporter and an
on-air contributor to CNBC. And if you're like me, you're trying to figure out how artificial
intelligence is changing the business world and our lives. So each week on Big Technology,
I bring on key actors from companies building AI tech and outsiders trying to influence it,
asking where this is all going to come from places like Nvidia, Microsoft, Amazon and plenty more.
So if you want to be smart with your wallet, your career choices, and meetings with your
colleagues and at dinner parties, listen to Big Technology podcast wherever you get your podcasts.
Plaintiff had virtually no time to process or further determine what happened to her, as her
flight back to Oklahoma left at 3.50pm, October 17th, 2024. Less than 24 hours after Plaintiff arrived
in New York City. The day after Plaintiff returned home from New York, she received a call from a New
York area code with an anonymous female caller. The anonymous female caller asked to speak to Plaintiff.
The anonymous female caller then threatened Plaintiff, telling her that any attempts to pursue
anything about Plaintiff's assault would be futile because Defendant Combs was a celebrity,
and that Plaintiff was just wasting her time. Plaintiff was confused and scared as she did not know
what had happened to her. Plaintiff hearing this from an anonymous female caller was further jarring
and traumatizing, as Plaintiff learned that not only was she viciously assaulted,
leading to her waking up at the hospital, but that Defendant Combs was involved and Plaintiff
would be unable to seek justice for her injuries because of Defendant Combs' celebrity status.
When Plaintiff tried to ask the anonymous female caller her name and how she obtained Plaintiff's
phone number, the anonymous female caller hung up. When Plaintiff tried to call the number back,
the number was disconnected. For approximately a week after Plaintiff returned home,
she fell constant pain in the inside and outside of her vagina,
pain she believed was from rough intercourse. However, Plaintiff had no memory of engaging in
intercourse with anyone. Plaintiff did not seek medical treatment or otherwise report her
assault to law enforcement because she was scared and confused. First, because she did not know what
exactly happened to her, second, because of the threats she received from the anonymous female
caller of Defendant Combs' involvement and it being a waste of time due to his celebrity status.
Plaintiff became severely depressed and felt shamed despite not fully remembering what happened to her.
Plaintiff felt betrayed by Defendants, specifically Defendant Combs, as J.C.
BBE Atlantic Crowbar and K.Jams, because she believed attending a party thrown by Defendant Combs
would be a safe environment. Plaintiff felt betrayed by Defendants, as J.C. BBE Atlantic Crowbar
and K.Jams, because they felt a protector despite creating, promoting and financing a contest that
led to her injuries and learned her to an unsafe place without warning. The assault in fear
after the assault led Plaintiff into a talisman of anxiety and depression. Plaintiff was unable to
maintain employment or otherwise be productive member of society for at least a year after her
assault in Battery in New York City. Plaintiff believed Defendants committed the assault and
battery against her solely because of her gender. Plaintiff has been reminded of her assault by
Defendant Combs as he is an inescapable presence in music, television and film. Plaintiff also
has experienced intimacy issues, struggling to maintain emotional and romantic relationships.
Defendant Combs has altered the trajectory of Plaintiff's life. To this day, Plaintiff
experiences bouts of depression, anxiety, body image issues, feelings of worthlessness,
and intimacy issues because of her trauma stemming from the assault. Plaintiff feared for their
violence and or retaliation from Defendant Combs in filing this lawsuit, but since Defendant Combs has
been incarcerated with no bond, Plaintiff feels safe to seek redress for her injuries. Plaintiff
seeks justice for herself and for any other Defendant Combs victims, including the countless victims
who have already filed suit against the Defendant. All right, we're going to wrap up right here,
and in the next episode, we're going to pick up with the first cause of action. All of the
information that goes with this episode can be found in the description box. Hi, this is Alex
Cantrowitz. I'm the host of Big Technology podcast, a long-time reporter and an on-air contributor
to CNBC. And if you're like me, you're trying to figure out how artificial intelligence
is changing the business world and our lives. So each week on Big Technology,
I bring on key actors from companies building AI tech and outsiders trying to influence it,
asking where this is all going. They come from places like Nvidia, Microsoft, Amazon,
and plenty more. So if you want to be smart with your wallet, your career choices,
and meetings with your colleagues and at dinner parties, listen to Big Technology podcast
wherever you get your podcasts.
Beyond The Horizon
